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Standard Interpretations
07/20/1992 - Cellulose nitrate and the PSM Standard.
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• Standard Number: 1910.119

July 20, 1992 

MEMORANDUM FOR:     JAMES W. STANLEY
                   Regional Administrator

FROM:               PATRICIA K. CLARK, Director
                   Directorate of Compliance Programs

SUBJECT:            Aqualon Company's Request for Clarification Concerning
                   Process Safety Management (PSM) Standard,
                   29 CFR 1910.119
This is in response to your request of May 5 on this subject, regarding whether the Aqualon Company's cellulose nitrate process is covered under 29 CFR 1910.119. We concur with the Regional position on this question.

The company manufactures cellulose nitrate in a concentration greater than 12.6% nitrogen; water is then added in further processing and transfer of the material. The finished product is a mixture containing greater than 23% water, which the company indicates will not burn.

Nevertheless, as you have stated, Appendix A of the standard lists cellulose nitrate in concentrations of greater than 12.6% nitrogen as a chemical which presents a potential for a catastrophic event at or above the threshold quantity of 2500 pounds. The standard does not distinguish between "wet" or "dry" cellulose nitrate.

Therefore, if the Aqualon Company's process involves cellulose nitrate in a concentration greater than 12.6% nitrogen, with the total quantity of the mixture or solution at or above the threshold quantity--no matter what percentage of water may be used in treatment--the process is covered under the requirements of 29 CFR 1910.119.

If you have further questions on this, please contact William Smith, Division of Safety Guidance Development, at 202-523-8041.

cc: Leo Carey, Office of Field Programs

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